The defendant is charged [in count __]
with criminal impersonation. The statute defining this offense reads in
pertinent part as follows:

a person is guilty of criminal
impersonation when (he/she) pretends to be a public servant other than a sworn
member of an organized local police department or the division of state police
within the department of emergency services and public protection, or wears or displays without authority
any uniform, badge or shield by which such public servant is lawfully
distinguished, with intent to induce another to submit to such pretended
official authority or otherwise to act in reliance upon that pretense.

For you to find the defendant guilty
of this charge, the state must prove the following elements beyond a reasonable
doubt:

Element 1 - ImpersonationThe first element is that the
defendant <insert as appropriate:>

by (his/her) words
or conduct, pretended to be a public servant other than a sworn member of an
organized local police department or the division of state police within the
department of emergency services and public protection.

wore or displayed
without authority a uniform, badge or shield by which a public servant is
lawfully distinguished.

A "public
servant" is an officer or employee of government or a quasi-public
agency, elected or appointed, and
any person otherwise paid or unpaid, in performing a governmental function.

Element 2 - IntentThe second element is that by such
action, (he/she) intended to induce another to submit to such pretended official
authority or otherwise to act in reliance upon such pretended authority. A
person acts "intentionally"
with respect to a result when (his/her) conscious objective is to cause such
result. <See
Intent: Specific, Instruction 2.3-1.>

Conclusion

In summary, the state must prove
beyond a reasonable doubt that the defendant 1) (pretended to be <insert type
of public servant> / wore or displayed <insert allegations>), and 2)
intended to induce another to submit to such pretended official authority or
otherwise to act in reliance upon such pretended authority.

If you unanimously find that the state
has proved beyond a reasonable doubt each of the elements of the crime of
criminal impersonation, then you shall find the defendant guilty. On the other
hand, if you unanimously find that the state has failed to prove beyond a
reasonable doubt any of the elements, you shall then find the defendant not
guilty.
_______________________________________________________

The fact that the uniform, badge or
shield was not authentic is irrelevant. "The goal of the statute is to prohibit
criminal impersonation. Among other things, the statute prohibits an individual
from using a badge with the intent of inducing another to submit to authority
that he or she does not possess. Because the state proved beyond a reasonable
doubt that the defendant used a badge that appeared to lawfully distinguish him
and that he used the badge in the manner proscribed by the statute, we are
unable to see how the issue of the badge's lineage or authenticity bears on the
goals that the legislature sought to achieve." State v. Guadalupe, 66
Conn. App. 819, 828 (2001), cert. denied, 259 Conn. 902 (2002).